Response to consultation on Implementing Technical Standards on amended disclosure requirements for ESG risks, equity exposures and aggregate exposure to shadow banking entities

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1. Do you have any comments on the proposed set of information for Large institutions?

2. Do you have any comments on the simplified set of information for Other listed institutions and Large subsidiaries?

3. Do you have any comments on the simplified set of information proposed for SNCI and other non-listed institutions?

4. Do you have any comments on the proposed approach based on materiality principle to reduce the frequency (from semi-annual to annual) of specific templates (qualitative, template 3, and templates 6-10) for large listed institutions?

5. Do you have any comments on the transitional provisions and on the overall content of section 3.5 of the consultation paper?

6. Do you have any comments on the proposed amendments to Table 1 and Table 3?

7. Do you have any further suggestions on Table 1A?

8. Do you have any comments on the proposed additions and deletions to the sector breakdown?

9. Do you have any views with regards to the update of the templates to NACE 2.1?

10. Do you have any views with regards to NACE code K – Telecommunication, computer programming, consulting, computing infrastructure and other information service activities, and in particular K 63 - Computing infrastructure, data processing, hosting and other information service activities, whether these sectors should be rather allocated in the template under section Exposures towards sectors that highly contribute to climate change?

11. Do you have any comments on the inclusion of row “Coverage of portfolio with use of proxies (according to PCAF)”?

We propose aligning the disclosure metric “coverage of portfolio with use of proxies” with the PCAF Data Quality Score, rather than relying on a percentage-based coverage indicator. While both approaches aim to reflect the extent of proxy usage, the PCAF scoring system provides additional granularity by accounting for the quality and reliability of the underlying data.

Importantly, the PCAF Data Quality Score is widely recognized and used across the financial sector, which would facilitate implementation and comparability across institutions. In line with the above, we also propose to replace Column K (gross carrying amount percentage of the portfolio derived from company-specific reporting) with the PCAF Data Quality Score.

Additionally, for Column K and Column I (row 75), we recommend specifying which emission scope (Scope 1, 2, or 3) the data relates to. The methodology for GHG emissions can differ between scopes, and without this clarification, the interpretation of proxy coverage and data quality may be inconsistent.

12. Do you have any further comments on Template 1?

13. Do you have any comments or alternative suggestions for SNCIs and other institutions that are not listed, regarding the sector breakdown?

14. Do you have any additional suggestions how to adjust Template 1A for SNCIs and other institutions that are not listed?

15. Do you have any further comments on Template 1A?

16. Should Template 2 in addition include separate information on EPC labels estimated and about the share of EPC labels that can be estimated?

17. Should rows 2, 3 and 4 and 7, 8 and 9 for the EP score continue to include estimates or should it only include actual information on energy consumption, akin to the same rows for EPC labels?

18. Do you have any comments on the inclusion of information on covered bonds?

19. Do you have any comments on the breakdown included in columns b to g on the levels of energy performance?

20. Do you have any further comments on Template 2?

21. Do you have any comments on Template 3?

We are happy with the proposed changes to Template 3, particularly the removal of fixed sector classifications and the opportunity for institutions to define the relevant sectors themselves. This flexibility allows for a more accurate reflection of portfolio composition and sectoral relevance in the context of transition planning.

To further enhance the usefulness of the template, we suggest adding a link with Template 1, specifically by indicating how much of the exposure towards high-emitting sectors is covered by a climate-related target. For example by including the percentage of the total portfolio that is covered by such targets (next to only total exposures), to provide a broader view of the institution’s overall transition strategy and ambition level.

As a second remark, while the template seems to imply that only the IEA NZE2050 pathway can be used, the accompanying guidance states that other transition pathways may also be applied. Therefore, we propose to remove the specific reference to IEA NZE2050 from the column headers, to avoid confusion and ensure consistency with the broader guidance.

22. Do you have any comments with the proposals on Template 4 and the instructions?

23. Do you have any views on whether this template could be improved with some more granular information in the rows, by requesting e.g. split by sector of counterparty or other?

We would refrain from adding more granular information in Template 4, such as a split by sector of counterparty or similar breakdowns. Increasing the level of detail in this template could lead to situations where disclosed data becomes too easily attributable to individual companies, especially in cases where portfolios are concentrated or contain unique exposures. Maintaining a balance between transparency and data protection is essential. Therefore, we recommend keeping Template 4 at its current level of aggregation to avoid unintended breaches of confidentiality.

24. Do you have any further comments on Template 4?

Our suggestion would be to work with a single, standardized list of the top 20 emitters, rather than allowing banks to select their own list. This approach would significantly enhance the comparability and uniformity of the data provided across institutions.

25. Do you have any comments on the proposal using NUTS level 3 breakdown for Large institutions and NUTS level 2 for Other listed institutions and Large subsidiaries? Would NUTS level 2 breakdown be sufficient for Large institutions as well?

26. Do you have any comments on the instructions for the accompanying narrative and on whether they are comprehensive and clear?

27. Do you have any further comments on Template 5 and on its simplified version Template 5A?

28. Do you have any comments on the proposal to fully align templates on the GAR, that is, templates 7 and 8, with those under the Taxonomy delegated act by replacing the templates with a direct cross reference to the delegated act?

29. Do you have any comments on the proposal related the BTAR and to keep it voluntary?

30. Do you have any comments regarding the adjustments to template 10?

31. Do you have any further comments on the Consultation Paper Pillar 3 disclosures requirements on ESG risk?

32. Are the new template EU SB 1 and the related instructions clear to the respondents? If no, please motivate your response.

33. Do the respondents agree that the new template EU SB 1 and the related instructions fit the purpose and meet the requirements set out in the underlying regulation?

34. Are the amended template EU CR 10.5 and the related instructions clear to the respondents? If no, please motivate your response.

35. Do the respondents agree that the amended template EU CR 10.5 and the related instructions fit the purpose and meet the requirements set out in the underlying regulation?

36. Do the respondents consider that the “mapping tool” appropriately reflects the mapping of the quantitative disclosure templates with supervisory reporting templates?

Name of the organization

Coöperatieve Rabobank U.A.